104 Additional Information We Are Kenanga Leadership Message Our Sustainability Approach How We Are Governed Financial Statements Shareholders’ Information and conscientiousness, and must not put themselves in an obligated or compromised position in all dealings with each other as well as with external parties. The commitment of all employees to comply with the Employees Ethics Code is procured and refreshed where all new recruits are required to acknowledge understanding on expectation in regard to the Code while similar acknowledgement is obtained from the existing employees annually. • Code of Conduct for Vendors Kenanga treats our vendors fairly through conduct of business and behaviour that are consistent with our ethical values and principles. It is also the goal of Kenanga to always collaborate with our vendors towards contributing to the sustainable development goals. The Code of Conduct for Vendors (“Vendors Conduct Code”) reflects the values of ethics and integrity of Kenanga and is principled on ensuring the highest standards of professional conduct from its vendors. The Vendors Conduct Code sets out the minimum standards of general business conduct and ethical practices expected of all vendors who engage with or undertake work for Kenanga. By requiring vendors to commit to the same, Kenanga takes the step towards ensuring that the parties it deals with are similarly committed to exemplary values. • Managing Conflict of Interest The Group Conflict Management Policy (“Conflicts Policy”) sets forth the policies and guiding principles in managing conflicts of interest. The Conflicts Policy introduces two (2) broad categories of personal and business-related conflicts of interest and detail out the situations that may constitute the same. This was done to make clear the importance of identifying the various potential conflicts that may arise in the execution of the responsibilities entrusted upon the employees. In addition to the Conflicts Policy, the Guidance on Conflict of Interest (“Conflicts Guidance”) was adopted to provide further guidance towards identifying and managing personal and business-related conflicts of interest. The Conflicts Guidance further reinforces the primary responsibility of all parties in Kenanga in identifying, reporting and managing conflicts of interest. The employees as well as department, divisions and subsidiaries within Kenanga are required to declare any actual, potential or perceived conflicts of interest, be it personal or business-related. This requirement is premised on the basis that such conflicts could interfere with the ability to act objectively and in the best interest of Kenanga, and in order for any conflicts to be properly managed by taking the necessary steps. • Gifts, Entertainment and Hospitality The Group Gifts, Entertainment and Hospitality Policy (“GGEH Policy”) serves as one of the control measures involving situations that could be deemed as conflict of interest or could potentially give rise to the appearance of conflict of interest in relation to any business dealings between Kenanga and external parties. The GGEH Policy clarifies the position of Kenanga in regard to giving and acceptance of gifts, entertainment and hospitality in the conduct of business while ensuring the highest standards of ethics and integrity are preserved. In addition to prescribing specific threshold limits and approval requirements in relation to gifts, entertainment and hospitality that employees of Kenanga may offer or receive, the GGEH Policy also stipulates that employees are strictly prohibited from offering or accepting gifts, entertainment and hospitality with a view to improperly cause undue influence on any other party in exchange of any business dealings. • Chinese Wall and Insider Trading Kenanga has an obligation to ensure that information pertaining to its business and clients, and all activities of the clients remain confidential. As such, the Group Chinese Wall Policy (“Chinese Wall Policy”) is established to prevent and/ or control the flow of confidential and material nonpublic and price sensitive information (“MNPI”) especially between the divisions and departments of Kenanga. The Chinese Wall Policy establishes guidelines to avoid the risk of possible breach of insider trading provisions and prevent possible conflicts of interest issues. In managing the exposure or misuse of confidential and MNPI, personal trading of the employees is being monitored. This allows early detection of any sign of insider trading and assists to avoid potential violations of insider trading regulations and therefore, contribute to overall market integrity. ETHICS AND COMPLIANCE STATEMENT
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